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Central Intelligence Agency
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4520437
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Central Intelligence Agency
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Philip W. Buchen Files
Philip Buchen's General Subject Files
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Central Intelligence Agency. (12/04/1981 - )
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The original documents are located in Box 2, folder "Central Intelligence Agency" of the Philip Buchen Files at the Gerald R. Ford Presidential Library. Copyright Notice The copyright law of the United States (Title 17, United States Code) governs the making of photocopies or other reproductions of copyrighted material. Gerald R. Ford donated to the United States of America his copyrights in all of his unpublished writings in National Archives collections. Works prepared by U.S. Government employees as part of their official duties are in the public domain. The copyrights to materials written by other individuals or organizations are presumed to remain with them. If you think any of the information displayed in the PDF is subject to a valid copyright claim, please contact the Gerald R. Ford Presidential Library. Digitized from Box 2 of the Philip Buchen Files at the Gerald R. Ford Presidential Library THE WHITE HOUSE WASHINGTON FOR: DAVID BELIN FROM: PWB Attached are sent to you for prompt handling, 75 we discussed on the tolephone. capies with this of send note originals ADB to FORD We should mabel Хелор at 710 Jackson Plac ERAL 20 by messenger. C/A January 1975 Dear mr President Hoid, I have been trying for two years to inform someone in regard to C.I.A. involvement on persons. As I have personally been a victim as well as my husband. A victim of a false report made by an agent. It is to long and involved to put down here. I was told by one informant that Richard Helms and Vervon Walters know of this incident. I have written to the White House as well as some Sentors in the past about this, without any satisfing responds. Ihope now that in light of today proplem someone is ready to listen Most sincerely, Jeanne M.Rolusta FORD i LIBRARY 07V839 Mr Buchen, l hope you well take a minute and have the President read this. at is brief, but the information l was subject to is to involved to put down at this moment But & strongly biline the independence and roots of our Country are in danger if many of these wrong doing for personal sansfaction are let to continue. It is a panful growing process we are in night new. But I believe men of honor, truth and dedication are ile ones who can lead us to survive and continue to grow, Jeanne Gratefully M. Roberts P.S. l shall in about one with send to several Senstors a copy of this letter - as well as to a couple of foundicks if it be the only way to bring into the open John Tuesday 1/14/75 1:55 David Belin suggested you look at 5 App. USCA, Sec. 4(b)(1). He will call you on it -- would like to discuss. FORDO LIBRARY (see attached xerox) ,M 07V839 FEDERAL ADVISORY COMMITTEE ACT of Title 3, The President], and as Presi- gress required by section 6(c) of the act; dent of the United States, it is hereby and ordered as follows: (3) prescribe administrative guidellnes APPENDIX I Section 1. The heads of all executive and management controls for advisory departments and agencies shall take ap- committees composed wholly of full-time propriate action to assure their ability to officers or employees of the Federal Gov- comply with the provisions of the net. FEDERAL ADVISORY COMMITTEE ACT ernment (inter-agency committees not See. 2. The Director of the Office of subject to the provisions of the act), as Management and Budget shall: well as for advisory committees covered (1) perform, or designate, from time to Pub.L. 92-463, Oct. 6, 1972, 86 Stat. 770. by the act. time, other officers of the Federal Gov- Sec. 3. Section 8(4) of Executive Order Sec. Sec. ernment to perform, without the approv- No. 11671 of June 5, 1972, is hereby re- 1. Short title. 9. Establishment and purpose of ad- al, ratification, or other action of the voked and the remainder of that order 2. Findings and purpose. visory committees; publication in President, the functions vested in the shall be deemed to be superseded effec- 3. Definitions. Federal Register; charter: filing, President by the act, except the function tive as of the expiration of ninety days 4. Applicability; restrictions. contents, copy. of making the annual reports to the Con- following the date of my approval of the 5. Responsibilities of Congressional 10. Advisory committee procedures; gress required by section 6(c) of the act; act. committees; review; guidelines. meetings; notice, publication in (2) prepare for the consideration of the RICHARD NIXON 6. Responsibilities of the President; re- Federal Register; regulations; President the annual reports to the Con- port to Congress: annual report to minutes: certification; annual re- LIBRARY Congress; exclusion. port; Federal officer or employee, § 3. Definitions. 7. Responsibilities of the Director, Of- attendance. fice of Management and Budget; 11. Availability of transcripts; "agency For the purpose of this Act- Committee Management Secretariat, proceeding". establishment; review; recom- 12. Fiscal and administrative provisions; (1) The term "Director" means the Director of the Office of Man- mendations to President and Con- recordkeeping; audit; agency sup- agement and Budget. gress; agency cooperation; per- port services. formance guidelines; uniform pay 13. Responsibilities of Library of Con- (2) The term "advisory committee" means any committee, guidelines; travel expenses; ex- gress; reports and background commission, council, conference, panel, task force, or other similar pense recommendations. papers; depository. 8. Responsibilities of agency heads; 14. Termination of advisory committees; group, or any subcommittee or other subgroup thereof (hereafter in Advisory Committee Management renewal; continuation. this paragraph referred to as "committee"), which is- Control Officer, designation. 15. Effective date. (A) established by statute or reorganization plan, or § 1. Short title (B) established or utilized by the President, or This Act may be cited as the "Federal Advisory Committee Act". (C) established or utilized by one or more agencies, in the interest of obtaining advice or recommendations for the Presi- § 2. Findings and purpose dent or one or more agencies or officers of the Federal Government, except that such term excludes (1) the Advisory Commission on In- (a) The Congress finds that there are numerous committees, boards, tergovernmental Relations, (ii) the Commission on Government Pro- commissions, councils, and similar groups which have been established to advise officers and agencies in the executive branch of the Federal Gov- curement, and (iii) any committee which is composed wholly of full- time officers or employees of the Federal Government. ernment and that they are frequently a useful and beneficial means of (3) The term "agency" has the same meaning as in section 551 furnishing expert advice, ideas, and diverse opinions to the Federal Gov- (1) of Title 5. ernment. (4) The term "Presidential advisory committee" means an ad- (b) The Congress further finds and declares that- visory committee which advises the President. (1) the need for many existing advisory committees has not been adequately reviewed; § 4. Applicability; restrictions (2) new advisory committees should be established only when (a) The provisions of this Act or of any rule, order, or regulation they are determined to be essential and their number should be kept promulgated under this Act shall apply to each advisory committee except to the minimum necessary; to the extent that any Act of Congress establishing any such advisory (3) advisory committees should be terminated when they are no committee specifically provides otherwise. longer carrying out the purposes for which they were established; (4) standards and uniform procedures should govern the estab- (b) Nothing in this Act shall be construed to apply to any advisory lishment, operation, administration, and duration of advisory com- committee established or utilized by- mittees; (1) the Central Intelligence Agency; or (2) the Federal Reserve System. (5) the Congress and the public should be kept informed with re- spect to the number, purpose, membership, activities, and cost of ad- (c) Nothing in this Act shall be construed to apply to any local civic group whose primary function is that of rendering a public service with vlsory committees; and respect to a Federal program, or any State or local committee, council, (6) the function of advisory committees should be advisory only, board, commission, or similar group established to advise or make recom- and that all matters under their consideration should be determined, mendations to State or local officials or agencies. in accordance with law, by the official, agency, or officer involved. EXECUTIVE ORDER NO. 11686 § 5. Responsibilities of Congressional committees; review; guide- lines Oct. 7, 1972, 37 F.R. 21421 COMMITTEE MANAGEMENT (a) In the exercise of its legislative review function, each standing I have approved the Federal Advisory Appendix] in effect, supersede and re- committee of the Senate and the House of Representatives shall make a Committee Act [set out in this Appendix] place the committee management stand- continuing review of the activities of each advisory committee under its which provides standards for the estab- ards and procedures set forth in Execu- 11471 which T issued on jurisdiction to determine whether such advisory committee should be THE WHITE HOUSE WASHINGTON February 11, 1975 MEMORANDUM FOR: JANE DANNENHAUER FROM: PHILIP BUCHEN T.W.B. Kindly arrange to obtain the necessary additional security clearances for Kenneth Lazarus so that he may review classified materials of the CIA and other agencies or departments engaged in foreign intelligence operations. It is necessary that Mr. Lazarus as a member of my staff assist me in the review of certain such materials from time to time. FORD i LIBRARY GERALD THE WHITE HOUSE WASHINGTON Feb. 13, 1975 To: Mr. Areeda From: Eva Mr. Buchen asked me to give this to you. FORD i LIBRARY GRAALD COMMISSION ON CIA ACTIVITIES WITHIN THE UNITED STATES Washington, DC 20500 Nelson A. Rockefeller, David W. Belin, Chairman Executive Director John T. Connor C. Douglas Dillon Erwin N. Griswold February 11, 1975 Lane Kirkland Lyman L. Lemnitzer Ronald Reagan Edgar F. Shannon, Jr. TO: Philip Buchen FROM: David W. Belin SUBJECT: William Miller and Jack Boos Meeting - February 11, 1975 On February 11, 1975, Joseph O'Leary, our legisla- tive liaison, and I met William Miller for lunch. Miller is the Chief-of-Staff for the Senator Church Committee. According to Miller, within two weeks his staff will be in "3/4" gear. He plans to have a total staff of around 40 of whom 10-12 will be lawyers. The initial work will concentrate on re- view of documents, interviews, and what Miller called "depositions". He said he does not plan to have any hearings for several months. He also said he did not think the September deadline could be met and instead thought the investigation would take at least the rest of this year. The thrust of his investigation will include the whole range of intelligence gathering agencies and will go into basic matters of policy including whe- ther or not there is a need for all of the agencies, how much the cost is, what the results are, related public policy matters, rights of privacy, questions pertaining to the propriety of operations, etc. He said the Committee would operate out of a room that he referred to as the "auditorium" which he thought gave the best security. He said there would be rigid standards imposed to try to seal off any leaks. These standards would include hav- ing everything in a central filing area with a check out system permitted to particular people so that REFORD GERALD LIBRARY 2. leaks occurred the source of the leaks could be readily ascertained. Xeroxing would be severely limited. The meeting with Jack Boos, who works with Congress- man Nedzi, was relatively short. Boos (pronounced Bows) said that it would be a month before the House Committee got organized. He was not certain that Nedzi would be the Chairman. William Miller was present during part of the meeting. When I ques- tioned about possible leaks, the analogy of the Joint Atomic Energy Committee was given as an ex- ample of a "leak proof" committee. When I asked why the intelligence investigation was not being done by a Joint Senate/House Committee, the re- joinder was that it was too difficult to arrange because of matters of protocol, etc. I did not enter into any specific discussion with either Miller or Boos involving any exchange of information. CC: Vice President Nelson A. Rockefeller Some items in this folder were not digitized because it contains copyrighted materials. Please contact the Gerald R. Ford Presidential Library for access to these materials. Rowland Evans and Robert Novak Thursday. pril 17, 1975 Protecting the CIA THE WASHINGTON POST Tucked into President Ford's speech to Congress, and ignored in the emo- tional controversy over Vietnam, was a carefully worded warning that secret operations of the Central Intelligence Agency (CIA) must be protected from "altered" congressional oversight that threatens "essential secrets." Mr. Ford's purpose: repeal of an oversight provision stuck into a new law last December. That provision requires the President to notify "ap including the Wednesday 6/18/75 C/Apress 4:45 Dave Crock of the Washington Post called and said 223-7460 he had been talking with Mr. Clapper of the CIA Commission, who indicated that Belin recommended some of the testimony be released ** but didn't know exactly to whom the recommendation had been made at the White House. I tried to reach Mr. Clapper but he was not in his office. I advised Mr. Crock that I had seen nothing come in. He wanted to know to whom it would have come if a recommendation of that nature came from Belin. I told him I didn't know if it would have come to the President or to whom, but perhaps he could check with Mr. Clapper and get more information. FORD is LIBRARY 07V830 CENTRAL INTELLIGENCE AGENCY WASHINGTON, D.C. 20505 12 November 1975 The Honorable Philip Buchen Counsel to the President The White House Washington, D. C. 20500 Dear Phil: Some weeks ago we chatted about the Civil Rights Division investigation of some 46 CIA officers and former employees who were involved in the warrantless entry of a Fairfax, Virginia, photographic studio. At that time, I expressed some concern as to whether, as a matter of law, convictions could be obtained on the subject. The enclosed memorandum may be of some interest to you. Last week a $12 million suit was filed in Federal District Court by the couple subject to the entry. If the Department of Justice continues its criminal investigation, I understand that it will neither defend the civil suit nor authorize payment of legal fees to private counsel. Thus, if as I believe, no criminal prosecution is feasible, it would be very helpful to the 46 defendants in the civil suit for a prompt decision to be made by Justice. Sincerely, Matchell Rogovin Mitchell Rogovin Special Counsel to the Director Attachment REVOLUTION LIBRARY GERALD ? FORD AMERICAN BICENTENNIAL 1776-1976 FORD LIBRARY Body of Slain CIA Man Is Returned Home GERALD By Jeremiah O'Leary The Washington Star Tuesday, December 30, 1975 Washington Star Staff Writer In the half-light of a cold winter dawn, a young Marine officer stood at rigid salute this morning as an honor guard marched in slow-step down the ramp of an Air Force plane bringing home the body of his mur- dered father, CIA officer Richard Welch. C/A Consultants THE WHITE HOUSE WASHINGTON January 2, 1976 MEMORANDUM FOR: JACK MARSH FROM: PHIL BUCHEN T. Attached is a copy of an article entitled "The CIA and American Foreign Policy" by Ernest W. Lefever, which appeared in a recent issue of the "Lugano Review. " It occurs to me that this article deserves additional circulation and that we might want to see that copies are distributed to people in the Congress and to appropriate media people. It also occurs to me that Ernest Lefever may be a useful addition to the group we have used as consultants. cc: Max Friedersdorf Director William Colby Ambassador George Bush Mike Duval FORD is LIBRARY 9ERALD 2a THE WHITE HOUSE C/A. WASHINGTON February 3, 1976 Dear George: As you begin your tenure as DCI, I would like to call to your attention two individuals -- John Clarke and Marshall Miller -- who could be of some assistance to you. John Clarke retired from the CIA last summer as Associate Deputy to the DCI for the Intelligence Community; he is currently the Assistant Comptroller at Amtrak. At the Agency John was the de facto head of the Intelligence Community Staff. I worked closely with him during the early stages of the Congressional investigations and have consulted with him since then on a variety of intelligence matters. In my dealings with John, he impressed me as a man of exceptional intelligence, judgment, loyalty and common sense. I believe he still has much to give to the CIA and recommend him to you without any reservations whatsoever. I don't know Marshall Miller personally, but he is highly regarded by Jim Wilderotter of my staff. As you will note from his resume, Mr. Miller was with Bill Ruckelshaus both at EPA and the Department of Justice. He is quite interested in a position on your staff, and Jim feels his legal background and broad govern- ment experience would be particularly useful to you in view of the kinds of problems the Agency will be facing in this transitional period. Best regards. DECLASSIFIED E.O. 13526 (se amended) SEC 3.3 Sincerely, MR # 11-080;#2 CIA letter 9/21/11 By dal NARA, Date 2/3/12 Thil Philip W. Buchen Counsel to the President The Honorable George Bush Director of Central Intelligence Washington, D. C. LIBRARY GERALD ? FORD Enclosure ab Biography Marshall Lee Miller Marshall Lee Miller is Deputy Assistant Secretary for the Occupational Safety and Health Administration, which he joined in June 1975. Before taking this position, Mr. Miller was in private law practice in Washington, D. C., during 1970-1971 and 1974-1975. Prior to this, Mr. Miller was Associate Deputy Attorney General to William Ruckelshaus at the Department of Justice. From 1971 until 1973, he was at the Environmental Protection Agency where he was Special Assistant to Mr. Ruckelshaus for air pollution, toxic chemicals, and pesticides. He also served as EPA's Chief Judicial Officer, acting for the Administrator on appeals from decisions of the Administrative Law Judges. Mr. Miller attended Harvard College, Oxford University, Heidelberg University, and Yale Law School. He is the author of the "Environmental Law Handbook" and "Bulgaria in the Second World War." He also conducted a seminar at Yale University on the Arab-Israeli Conflict. Mr. Miller was born in Chattanooga, Tennessee, in 1942 and currently resides in Alexandria, Virginia. LIBRARY GERALD R. FORD C/A THE WHITE HOUSE WASHINGTON February 9, 1976 Dear Bill: Now that you have settled back to a time for contemplation and writing, I want to express my warm feelings and deep gratitude for your superb service in a most difficult government position during a most trying period. I derived much satisfaction and pleasure from working closely with you on some of the many problems you had over the last thirteen months. And my admiration for you is sure to be a lasting one. I do wish you much success and satisfaction in your current undertaking and in whatever new career you may decide to pursue after that. Sincerely, That Philip W. Buchen Counsel to the President The Honorable William E. Colby 5317 Briley Place Bethesda, Maryland 20016 LIBRARY GERALD R. FORD CENTRAL INTELLIGENCE AGENCY CENTRAL INTELLIGENCE AGENCY Dosfiling WASHINGTON, D.C. 20505 DEPARTMENT I February 23, 1976 The Honorable Philip W. Buchen Counsel to the President The White House Washington, D. C. 20500 Dear Phil: Thank you for your letter about John Clarke and Marshall Miller. I have heard good things about both of them, Right now, I see no openings that would be fully challenging for either of these men. I have told our personnel people that you have recommended them, and I will certainly keep in mind their interest in coming to the CIA. I don't like to be discouraging, but if there is any urgency in either case, perhaps it would be well to advise them that I don't foresee an immediate change in the situation on this end. Thanks for writing me about both Messrs. Clarke and Miller. Sincerely, George ay Bush Director FORD is GERALD LIBRARY ORIGINAL RETIRED FOR PRESERVATION 12:40 p.m. Friday, March 21 Listed below are the names and titles of the people Captain Howe (VP staff) promised you. Murphy Commission, working on: Dr. Francis Wilcox Executive Director, Commission on Organization of the Government for the Conduct of Foreign Policy 254-9850 Fisher Howe Deputy Executive Director 254-9850 FORD i LIBRARY 07V830 7 April 1976 MEMORANDUM FOR: Vice Admiral Daniel J. Murphy, USN Deputy to the DCI for the Intelligence Community FROM: Mitchell Rogovin, Special Counsel SUBJECT: Delivery of Documents to Congress 1. This is in reply to your 5 April memorandum for- warding the proposed form to be used to transmit documents to Congressional committees. Although I believe the form meets our needs, I am concerned that the Congressional committees may view the prohibition referred to in Para- graph 2 of the instructions as a frontal attack on the Committee's constitutional authority to receive infor- mation and to inform the Congress and the public. 2. The legend to be stamped on each document, "on loan from (Agency), not to be reproduced" (as amended by Seymour Bolten to include "or publicly disclosed with- out the express permission of the originating agency"), can generate a serious problem if this legend is indiscriminately placed on all documents. 3. Our experience regarding "loan documents" has been that committees will respect the concept when the document itself is not only highly classified but highly sensitive and, they are put on prior notice that access to the document will not be available unless such a condition is accepted by the committee. If all the materials sought by a Congressional committee (even if classified) are stamped with such a limitation, I can envision a refusal on the part of the committee to accept the documents. The Committee can then fall back on its subpoena power to attempt to secure the materials, unfettered by any condition. This leaves the Executive Branch in the unenviable position, if a subpoena is issued, of either complying with the demand or asserting executive privilege. FORD is LIBRARY GERALD 4. It would be my judgment that the "loan document" concept should be used sparingly and not automatically stamped on all materials. 5. I do not believe that the Department of Justice would be prepared to support the flat position that such a legend (even without the Bolten amendment) stamped on all of the documents was legally defensible. It would be my suggestion that before the form is placed in service that the Acting General Counsel seek the advice of the Justice Department regarding this matter. I believe this legal issue can better be resolved outside of the pressure of an actual demand by a committee chairman. Mutchell Rozousn Mitchell Rogovin Special Counsel to the Director CC: Philip Buchen Jack Marsh Mike Duval Antonin Scalia Seymour Bolten George Cary John Morrison FORD i LIBRARY ERALD C/A Friday 4/23/76 9:35 Dotty Cavanaugh said Mildred had a call from a General who is a friend of Mildred's, as well as the President's. He thinks the law regarding CIA is that one of the top two men has to be military. He is concerned about the Knoche nomination. The General will be calling again to ask if that is correct so Mildred would appreciate knowing. Top two can be civilians but by traditions it is usually military. FORD is LIBRARY GERALD C/A THE WHITE HOUSE WASHINGTON May 6, 1976 Dear George: In response to a request from your office, enclosed is a copy of the provision in the regulations governing the conduct of employees of the Executive Office of the President which relates to the acceptance of honoraria. My office has interpreted this provision as prohibiting the acceptance of honoraria for writings or appearances which in any way relate to subject matters involving the official's agency, even if the honorarium is to be given directly to charity by the sponsor. Please don't hesitate to contact me if you have additional questions of this nature. With best wishes, That Sincerely, Philip W. Buchen Counsel to the President The Honorable George Bush Director, Central Intelligence Agency Washington, D.C. 20505 FORD s LIBRAR. GLRALD (4) Accept unsolicited advertising or promo- information has been made available to the gen- tional materials such as pens, pencils, note pads, eral public or will be made available on request, calendars, or other items of nominal intrinsic or when the agency head gives written authoriza- value. tion for the use of non-public information on the (c) An employee shall not solicit contributions basis that the use is in the public interest. In ad- from another employee for a gift to an employee dition, an employee who is a Presidential ap- in a superior official position. An employee in a pointee covered by section 401 (a) of Executive superior official position shall not accept a gift Order No. 11222 of May 8, 1965, shall not receive presented as a contribution from employees receiv- compensation or anything of monetary value for ing less salary than himself. An employee shall not any consultation, lecture, discussion, writing, or make a donation as a gift to an employee in a appearance the subject matter of which is devoted superior official position (5 U.S.C. 7251). How- substantially to the responsibilities, programs, or ever, this paragraph does not prohibit a voluntary operations of his agency, or which draws substan- gift of nominal value or donation in a nominal tially on official data or ideas which have not amount made on a special occasion such as mar- become part of the body of public information. riage, illness, or retirement. (c) An employee shall not engage in outside (d) The Constitution (Art. 1, sec. 9, par. 8) employment under a State or local government, prohibits acceptance from foreign governments, except in accordance with applicable regulations except with the consent of Congress of any emolu- of the Civil Service Commission (Part 334 of 5 ment, office, or title. The Congress has provided for CFR Ch. I). the receipt and disposition of foreign gifts and (d) Neither this section nor § 100.735-14 pre- decorations in 5 U.S.C. 7342. See also Executive cludes an employee from: Order 11320, 31 F.R. 13739, and the regulations (1) Receipt of bona fide reimbursement unless pursuant thereto in 22 CFR Part 3 (as added, 32 prohibited by law, for actual expenses for travel F.R. 6569). Any such gift or thing which cannot and such other necessary subsistence as is com- appropriately be refused shall be submitted to the patible with this subpart and for which no Gov- Counselor for transmittal to the State Department. ernment payment or reimbursement is made. § 100.735-15 Outside employment and other However, an employee may not be reimbursed, and activity. payment may not be made on his behalf, for ex- cessive personal living expenses, gifts, entertain- (a) An employee shall not engage in outside ment, or other personal benefits, nor does it allow employment or other outside activity not com- an employee to be reimbursed by a person for patible with the full and proper discharge of the travel on official business under agency orders duties and responsibilities of his Government em- when reimbursement is proscribed by Decision ployment. Incompatible activities include, but are B-128527 of the Comptroller General dated not limited to: March 7, 1967. (1) Acceptance of a fee, compensation, gift. (2) Participation in the activities of national payment of expense, or any other thing of mone- or State political parties not proscribed by law. tary value in circumstances in which acceptance (See paragraph (o) of § 100.735-22 regarding pro- may result in, or create the apperance of, a con- scribed political activities.) flict of interests; or (3) Participation in the affairs of, or accept- (2) Outside employment which tends to impair ance of an award for a meritorious public contri- the employee's mental or physical capacity to per- bution or achievement given by, a charitable, form his Government duties and responsibilities in religious, professional, social, fraternal, nonprofit an acceptable manner. educational or recreational, public service, or civic (b) Within the limitations imposed by this sec- organization. tion, employees are encouraged to engage in (e) An employee who intends to engage in out- teaching, lecturing, and writing. However, an em- side employment shall obtain the approval, ployee shall not, either for or without compensa- through his official superior, of his agency head. tion, engage in teaching, lecturing, or writing that A record of each approval under this paragraph is dependent on information obtained as a result shall be filed in the employee's official FOR personnel of his Government employment, except when that folder. GERALD LIBRARY CENTRAL INTELLIGENCE AGENCY Foribuling 6 May 1976 NOTE TO: The Honorable Brent Scowcroft The Honorable William 6. Hyland The Honorable Philip W. Buchen The Honorable John 0. Marsh, Jr. Mr. Michael Duval Tony Lapham will be the new General Counsel at CIA starting 1 June. He has asked that this not be made public until we complete the security procedures at the Agency. I am very pleased about this and hope that you will enjoy working with Tony. Best regards, Cuy George Bush Director Att: Bie Sketch FORD is LIBRARY 07V830 Anthony A. Lapham, born San Francisco. Cal- ifornia, August 22, 1936; admitted to bar, 1962, Dis- trict of Columbia. Preparatory education. Yale University (B.A., 1958) ; legat education, George- toxie TT. C/A THE WHITE HOUSE WASHINGTON August 7, 1976 MEMORANDUM FOR: BARRY ROTH FROM: PHIL BUCHEN T. SUBJECT: CIA BUILDING At your request, I did talk to Tony Lapham on August 3rd about either cutting down the cost of the proposed project or having his office render an opinion that, because funds for the project have already been appropriated, no prospectus for the building is required. I assume he will get back in touch with either you or me on the matter. So that your file is complete, I enclose the Ogilvie memorandum to Jack Marsh. Attachment FORD is LIBRARY GERALD Copy to Schmults THE WHITE HOUSE Lozarus WASHINGTON A.ugust 31, 1976 ADMINISTRATIVELY CONFIDENTIAL MEMORANDUM FOR: PHIL BUCHEN/ED SCHMULTS FROM: JIM CONNOR SUBJECT: Recommended Telephone Call to Rep. Walter Flowers Confirming telephone call to your office, the President made the recommended telephone call to Representative Walter Flowers today concerning the private relief bill for the benefit of the survivors of Dr. Frank Olson and made the following notation: "Talked with Congressman Flowers. Sub-Committee action September 1/ full Committee following week. Foresees no problem." Please follow-up with appropriate action. cc: Dick Cheney Max Friedersdorf FORD is LIBRARY GERALD ITEM WITHDRAWAL SHEET WITHDRAWAL ID 00645 Collection/Series/Folder ID No : 001900077 Reason for Withdrawal : DR, Donor restriction Type of Material : LET, Letter (s) Creator's Name : Philip Buchen Receiver's Name : Deputy General Counsel of the CIA Description : he Rockefeller Commission re request for testimony before t Creation Date : 09/30/1976 Date Withdrawn : 05/09/1988 THE WHITE HOUSE WASHINGTON October 15, 1976 MEMORANDUM FOR: PHIL BUCHEN FROM: MIKE DUVAL D SUBJECT: Claim against the CIA Attached is a communication I received from the law firm of Sellers, Conner & Cuneo concerning a claim by the General Aircraft Corporation against the CIA. I have no idea why this was sent to me. I'm forwarding it to you for whatever action you deem appropriate. Attachment SELLERS, CONNER & CUNEO HOMER CUMMINGS JOHN D CONNER ATTORNEYS AND COUNSELORS (1870-1956) GILBERT A. CUNEO - ROBERT L ACKERLY 1625 K STREET, NORTHWEST HERBERT L. FENSTER) ASHLEY SELLERS WASHINGTON, D.C. 20006 JOEL P. SHEDD C. STANLEY DEES OF COUNSEL RAYMOND S.E. PUSHKAR JAMES J GALLAGHER (202) 452-7500 JOSEPH WAGER CHARLES A.O CONNOR. nr CABLE:SELCONCU WILLIAM J. SPRIGGS STEVEN L. BRIGGERMAN HARVEY G. SHERZER BUEL WHITE WILLIAM H. BUTTERFIELD ROBERT A. MANGRUM THOMAS L. PATTEN WILSIE H. ADAMS. JR. September 30, 1976 JEFFREY P. ALTMAN JOHN D. CONNER. JR. LAWRENCE S. EBNER D. MICHAEL FITZHUGH ALLEN B. GREEN E. SANDERSON HOE JOE G. HOLLINGSWORTH ALLAN W. MARKHAM THOMAS A. MAURO NEIL H. RUTTENBERG CERTIFIED MAIL D. JOE SMITH. JR. KENNETH W. WEINSTEIN RETURN RECEIPT Mr. George Bush Director Central Intelligence Agency Washington, D. C. 20505 Dear Mr. Bush: This firm represents General Aircraft Corporation, successor in name to Helio Aircraft Corporation. General Aircraft Corporation, hereinafter referred to as "GAC" or "Helio," is a manufacturer of light C/STOL aircraft, including models known as "Courier," "Stallion" and "U-5." This letter will constitute a claim made by and on behalf of General Aircraft Corporation against the United States and the Central Intelligence Agency under the Federal Tort Claims Act, 28 U.S.C. § 1365 and the Fifth Amendment to the Constitution, for a taking of private property for public use without just compensation. This letter will also constitute a claim made by and on behalf of GAC against: (1) corporations under the control of the Central Intelligence Agency and known as "proprietaries" of the Central Intelligence Agency, including Pacific Corporation, Civil Air Transport, Air America, Seven Seas Airlines, and Air Asia; and (2) individual employees of the Central Intelligence Agency and the proprietaries in their individual capacities and as officers, direc- tors or principal employees of the proprietaries under applicable anti-trust laws, including Sections 1 and 2 of the Sherman Act, 15 U.S.C. 1, 2 and under statutory and common law precedents covering tortious interference with business relations and unfair trade prac- tices. Further, this letter will also constitute notice to FORD of the intention of GAC to investigate and, as appropriate, act on con- flicts of interest and malpractice by professional organizations JBRARY who RECLASSISHED AUTHORITY RAC nLF- PB-1-2-1-6 9/21/05 BY Wn NLF, DATE 6/29/09 Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Two have and are determined to have represented the Central Intelligence Agency and its proprietaries (including their employees) while, with- out appropriate notice, also undertaking to represent GAC, its sub- sidiaries and related companies and its employees. Claim is made in the amount of $25 million against the parties identified above, jointly and individually, for the causes of action which have also been identified. This amount represents damages suffered by GAC. This does not, however, represent treble damages which may be assessed against the proprietaries. GAC further demands that the United States and its appropriate departments and agencies take all actions necessary in the United States and overseas to correct the actions and representations of all of those against whom this claim is made, which actions and representations compromised GAC's reputation and access to customers and markets and gave rise to the claim herein. We request prompt review, negotiation and settle- ment of this claim, since certain of the causes of action alleged are continuing and without settlement will continue to damage GAC. STATEMENT OF FACTS A. GAC Organization, Operation and Markets GAC was founded as Helio Corporation in 1949. In 1950 Mid- west Aircraft Corporation acquired Helio by an exchange of stock and changed its name, adopting the Helio Aircraft Corporation name. Sub- sequently, an aircraft manufacturing facility was established by the company in Pittsburgh, Kansas. In 1969 Helio acquired the assets of General Aircraft Corporation and adopted that corporation's name. The principal product of the company since its organization has been control short takeoff and landing (C/STOL) aircraft. The development and manufacture of such an aircraft incorporating very advanced and proprietary technologies was the purpose of the organ- ization of the company in 1949. Such an aircraft was developed with considerable success by the company in the 1950's and sold in substantial numbers in the 1950's and 1960's in the general aviation market and both to the United States and foreign governments. This aircraft was known as the Helio FORD is LIBRARY 9ERVID Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Three Courier (U-10). Starting in the 1950's and continuing into the early 1960's, sales of the Helio Courier were made from time to time both directly and indirectly to the Central Intelligence Agency. To the company's information and belief, such aircraft were used by the Central Intelligence Agency in support of covert operations conducted in areas where communications and transportation by normal means, including small aircraft with normal takeoff and landing constraints, would have been impossible. During the same period, personnel of the company undertook the development of comprehensive communications systems for use in primitive, remote and underdeveloped areas of the world. One such system was known as the Jungle Aviation and Radio Service (JAARS). A second system was developed and marketed through a company organ- ized by personnel of Helio and known as National Air Communications Systems, Inc. (Naircom). In the late 1950's and early 1960's the Central Intelligence Agency, as well as the Agency for International Development of the State Department, had participated significantly with Helio and its personnel in the development of these communica- tions systems, particularly in Latin America. Such systems were deployed successfully in Peru, Ecuador, Columbia and Panama. While it now appears that these systems and various features of them were used by the Central Intelligence Agency to carry on covert operations, the propriety of which is questioned, neither Helio nor its personnel were ever party to such operations, nor did they knowingly participate in such operations. During this period (the mid-1950's through the early 1960's) Helio had developed substantial and profitable markets for its Courier aircraft, both in domestic general aviation and with the United States and foreign governments. In addition to sales to the Central Intelligence Agency, sales were also made to the Air Force. Furthermore, substantial and potentially lucrative overseas markets were being developed. In particular, these markets were in emerging "third world" countries where the distinctive C/STOL and safe handl- ing features of the Helio Courier were of paramount importance and provided Helio with a considerable competitive advantage over other available aircraft. Markets for the aircraft thus were developed in Africa south of the Sahara, in the Pacific, including Micronesia, on the Indochina Peninsula and in Latin America. These markets paralleled the potential and developing mar- kets for the comprehensive air transport and communications systems which were being developed by Helio and its personnel. FORD is LIBRARY CERALD Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Four Restrictions on air field use in the United States appeared to limit commercial application of Helio's aircraft products and tech- nology. As a result, very substantial stress during the 1950's and 1960's was placed on overseas sales, particularly to underdeveloped nations and on military sales to the Department of Defense. By the early 1960's it had become apparent that a new generation of C/STOL aircraft, combining greater payload and increased engine power (in- cluding the use of turboprop engines), would be required. In response to this developing need, Helio undertook a program which led to the development and production of a new advanced C/STOL aircraft which became known as the "Stallion." This aircraft was developed at very substantial expense to Helio upon the determination that its estab- lished world markets, as well as its potential sales to United States Government agencies, particularly the Department of Defense, would return the investment with profit. In the early 1960's, Helio and its personnel devoted to comprehensive communications systems undertook intensive sales efforts in Africa and the Far East. These markets for Helio were real and viable, since the Helio products, including both the aircraft and communications systems, were unique and served significant needs in remote areas of underdeveloped countries. Moreover, Helio had estab- lished access to foreign government agencies and private investors who would have an interest in the purchase of Helio products. Thus, in the years 1960 through 1962, Helio undertook an intensive effort to sell its systems and aircraft in East Africa and the Congo. Nego- tiations between the company and African Government representatives were advanced to the point where substantial sales seemed assured. Negotiations regarding these sales were then suddenly cut off and Helio personnel were at the same time declared persona non grata and the opportunities were irrevocably lost. In 1961 Helio under- took an intensive sales effort in the Philippines. This effort was implemented through Naircom. The effort seemingly received the sup- port of the United States Embassy in Manila and the attached AID personnel. Again, this effort advanced to the point where the adop- tion of Helio's proposal was favorably recommended within the Philip- pine Government. However, the Helio proposal was once more suddenly rejected without explanation and the Helio representatives were warned by United States Government representatives not to continue negotia- tions or reenter the country. A similar pattern of facts, in each case resulting in Helio's personnel being excluded from the country, was repeated in Thailand, Vietnam, Laos, Nepal, Cambodia and Micronesia. Ultimately, Helio, Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Five its personnel, representatives and employed outside sales representa- tives were systematically excluded from all potential markets in underdeveloped and developing nations around the world. With the development of its "Stallion" aircraft, Helio sought to enter into the defense market, in which it had successfully engaged with its earlier "Courier" aircraft. Proposals in this connection were made from time to time, both to the Air Force and the Navy, but in each case the company was excluded or virtually excluded from the market, usually without adequate evaluation of its product but upon representations by Department of Defense personnel that they had re- ceived and reviewed evaluation information on the Helio products from other sources. The exclusion from its logical and historical markets has re- quired Helio to contract very substantially its operations in toto and to discontinue its aircraft manufacturing operations entirely. Such exclusion has, in sum, nearly destroyed the company's aircraft oper- ations. As is normal for companies manufacturing aircraft, Helio did carry on for many years a significant aircraft parts manufacturing function in support of its aircraft in the field. Again, in the 1960's this operation diminished significantly and inexplicably. Further- more, Helio received many complaints concerning the quality and reli- ability of its parts equipments which could not be substantiated by quality assurance testing and reliability controls. This combina- tion of circumstances, together with the disintegration of its markets for new aircraft, has resulted in a complete closing of all of Helio's aircraft operations. B. Interference by the Central Intelligence Agency, Its Proprietaries and Personnel in Helio Overseas Business Activities As has been alleged above, in the 1960's Helio was systemat- ically excluded from all of its foreign markets. While a conscientious effort was. made by Helio to determine the reasons for the failures of such markets, such a determination could never be adequately made. The recent investigations of CIA activities and those of CIA proprie- taries now discloses that Helio's exclusion from these world markets FORD i LIBRARY GERALD Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Six resulted directly and intentionally from the activities of the CIA, its proprietaries and personnel. It is now apparent that this exclu- sion resulted from a combination of the use of Helio's name and products by the CIA and its proprietaries with the conduct by the CIA in that connection of illegal, immoral and frequently violent actions against the foreign governments, their officials and citi- zens. In the late 1950's and early 1960's, Helio had, in addition to selling aircraft to the CIA, provided, from time to time, irregular assistance to CIA personnel, transporting them to various locations when doing so did not inconvenience Helio's marketing and maintenance operations. Such assistance was in no case provided covertly, nor were Helio personnel ever engaged in or aware of covert operations of the CIA, its proprietaries or personnel. In 1961 Helio had virtually completed a substantial sale to the Congo Government through negotiations, many of which were carried on directly with the Congo's then Government leader, Moise Tshombe. During this sales activity, Helio personnel had from time to time provided transportation to CIA representatives who apparently were attached to consular offices. In such instances, the transportation was provided to CIA personnel as "strangers" and no connection between the CIA personnel and the company was ever established by Helio. Nevertheless, it now appears that agents of the CIA obtained by forgery, misrepresentation, and other devices, credentials indicat- ing that they were sales employees of Helio, knowing well that such was not the case. These agents of the CIA used the "cover" of such misrepresentations to establish competing selling activities. More importantly, however, such "cover" was used by these agents to carry on illegal and immoral activities which ultimately resulted in the death of Government officials in the Congo and the fall of the exist- ing Government. These activities, conducted in the name of Helio, came to the attention of the Congo Government and its officials through their own intelligence and immediately resulted in the exclu- sion of Helio and its legitimate employees from any further operations. Similar activities were conducted by the CIA, its proprietar- ies and personnel, under cover of the company's name in Thailand, and in other countries on the Indochina Peninsula. There, agents employed directly by the CIA or its proprietaries, representing themselves as Helio employees, carried on activities frequently using Helio aircraft, a FORD GERALD LIBRARA Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Seven which involved the smuggling of illegal drugs, the murder of indige- nous people and clandestine operations against existing governments or gorilla movements. Such activities, when identified by the rele- vant governments, resulted in the immediate and permanent exclusion of Helio's legitimate personnel from those countries. In 1962 Helio was approached by a representative of a pro- prietary of the CIA who instructed Helio to turn over to the proprie- tary its worldwide selling operations. Helio refused and the subject was not thereafter raised by the Agency or its proprietary. In fact, Helio was assured that the proprietary lacked the authority to conduct such activities in Helio's name or in its own name. Nevertheless, it now appears that the CIA and its proprietaries, at that time and thereafter, undertook both to carry on activities in Helio's name and without Helio's knowledge, in all cases suppressing such facts and otherwise misrepresenting to Helio that such conduct was not taking place, and furthermore to compete with Helio by undertaking to market, through fraudulent and illegal means, competing products, identifying such marketing with the Government of the United States. It appears, moreover, that such activities were carried on both to advance the clandestine operations of the CIA and to provide means independent of the United States Government for financing such opera- tions and to garner a profit for the individuals involved. The aforesaid operations of the CIA, its proprietaries and their employees and agents included fraudulent traffic in the main- tenance of Helio aircraft owned and operated b.y the CIA and its pro- prietaries, the illegal manufacture and sale of equipments bearing the Helio name, and the marketing of competing products by CIA pro- prietaries, using as agents for such marketing uniformed officers of the United States Armed Services. Such activities by the CIA and its proprietaries actually included the establishment of an operation which illegally manufactured and marketed parts for Helio aircraft of inferior quality. Such activities also included the clandestine but worldwide marketing of competing aircraft, using as selling agents therefor personnel of the United States Air Force and a concerted campaign carried on with foreign governments and the United States Department of Defense to malign, misrepresent, and otherwise denigrate the worth and quality of Helio products. Upon information and belief, it was the purpose of such activities by the CIA and its proprietaries both to provide means for clandestine operations by CIA agents and to provide independent sources of revenue for CIA operations and for the individuals connected with those operations, without the necessity for recourse to the United States Government. Such activities, - FORD GERALD LIBRARY Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Eight undertaken as early as the early 1960's, were carried on clandestinely by the CIA, its proprietaries and personnel and at all times the CIA, its proprietaries and personnel denied to Helio the existence of such operations. C. Use of Central Intelligence Agency Personnel and Agents to Cover Alleged Illegal Operations In the late 1950's, when Helio began sales to the CIA of "Courier" aircraft, the CIA then insisted that Helio employ counsel cleared by the Agency to know of and pass upon such sales. Helio employed such counsel, upon the direct advice of the Agency. Such counsel continued to advise Helio throughout the 1960's and early 1970's, until the connection of such counsel to the CIA was discovered. At all times while advising Helio, such counsel was either employed by or in direct communication with, the CIA and at such times owed primary allegiance to the CIA. Such relationships created a conflict of interest which was manifested by advice to Helio, erroneous in fact and law, and known to be so by such counsel. In the early 1960's, when Helio began to encounter signifi- cant marketing problems in its overseas markets, all as aforesaid, Helio approached personnel of the CIA, including those responsible for aircraft purchase and operations and the Agency's Chief Counsel, both to complain and voice concern. On all such occasions, Helio was told that the Agency was conducting no illegal activities, nor any activities which would involve Helio, its name or products, and which would cause Helio any of the difficulties of which it complained. The Agency at all times denied any of the activities which have been recited above, notwithstanding the fact that the persons who made such denials were themselves personally engaged in such activities and directly responsible for them. CLAIM A. Claim Under The Federal Tort Claims Act This is a claim by General Aircraft Corporation under the Federal Tort Claims Act, 28 U.S.C. § 1346, et seq, against the Central Intelligence Agency, its agents and assigns for their wrongful inter- ference in the prospective business of the company. Pursuant GER LIBRARY Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Nine 28 U.S.C. § 1365, General Aircraft Corporation hereby notifies the Central Intelligence Agency of this claim in the sum certain amount of $25 million, by reason of such tortious interference in the com- pany's prospective business during the period set forth in the above Statement of Facts. 28 C.F.R. § 14.1 et seq. Notice is also hereby given that the facts alleged have been secreted, sequestered and intentionally withheld by the Agency, its agents and assigns, from the knowledge of General Aircraft Corporation and its employees from the dates when such activities are alleged to have occurred and until the time of and conclusion of proceedings before the United States Congress in or about June, 1976. The undersigned is authorized to present this claim under 28 C.F.R. § 14.3(e) on behalf of General Aircraft Corporation. Acts Of Interference In support of its claim under the FTCA for tortious inter- ference with the prospective business of Helio Aircraft Corporation, claimant would show the following: 1. The Naircom Corporation was unable to establish a market for its services in the Philippines in 1961, wholly as a result of the Agency's inter- ference with Naircom's efforts to establish a market in that area, as more fully set forth above. 2. Helio Aircraft Corporation was unable to obtain award of United States Government military con- tracts for the purchase of its aircraft due to the widespread and wrongful disparagement of Helio aircraft by the Agency. Such disparage- ment of Helio's product in particular resulted in the loss of otherwise competitive procure- ments from the Air Force and Navy, as more fully set forth above. 3. Helio Aircraft Corporation suffered extensive interference in the worldwide marketing of its aircraft as a consequence of the active spon- sorship of a Helio competitor, as more fully set forth above. Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Ten 4. The Agency's use and appropriation of Helio's corporate name and identity as a worldwide "cover" caused Helio Aircraft Corporation to suffer substantial stigmatizing and loss of sales in otherwise favorable markets. This stigmatizing and attendant loss of reputa- tion and sales ultimately impaired Helio's marketing of its aircraft, as more fully set forth above. Tortious Interference Helio Aircraft maintains that its right to pursue business without unjustified interference is a recognized property right pro- tected under the FTCA and breached by the United States in this instance when the Central Intelligence Agency and/or its proprietar- ies induced third persons not to enter into business relations with Helio Aircraft Corporation. It is firmly established that the Gov- ernment is not exempted as a wrongful interferer in a corporation's business. Helio Aircraft Corporation submits that in the face of the Agency's historical interference with the business of Helio, the Agency's conduct meets the requisites of the tort of interference with prospective business and, further, this action is not exempted from liability under § 2680 of Title 28 of the FTCA, which provides, in part: (a) Any claim arising out of assault, battery, false imprisonment, false arrest, malicious prosecution, abuse of process, libel, slander, misrepresentation, deceit, or interference with contract rights [is exempt from liability under the FTCA] (emphasis supplied). Established case law recognizes that governmental disparagement of a company's name, similar to the acts of the Central Intelligence Agency in this instance, creates a cause of action not exempted from the "interference with contract rights" exception of § 2680. Helio Aircraft Corporation contends that the Central Intel- ligence Agency's historical interference in its marketing of Helio aircraft and the Agency's worldwide disparagement of its name and reputation were tantamount to a "sanction" against Helio Aircraft LIBRARY GERALD ? FORD Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Eleven Corporation for Helio's failure to acquiesce to the Central Intelli- gence Agency and/or its proprietaries' demands that Helio serve as a "front" for Agency intelligence activities. The final product of this sanction was the substantial impairment of Helio's assets and its ability to maintain a viable business entity. The acts of the Central Intelligence Agency taken against Helio Aircraft Corporation have had a substantial adverse impact upon Helio's business relations with other private and governmental parties. The breadth of the scope of the Agency's interference with the prospective business of Helio, as described above, was wide and geographically dispersed. Against this factual posture that Helio possessed a right to compete for business without interference from the government or its proprietaries, Helio will show: (1) Existence of a valid business relationship or expectancy of the same prior to Agency interference; (2) Knowledge of this relationship or expectancy on the part of the Central Intelligence Agency or its proprietaries; (3) An intentional interference by the Central Intelligency Agency, in both prospective for- eign and domestic procurements, inducing or causing a breach or termination of the rela- tionship or its expectancy; and (4) Attendant damage to Helio Aircraft Corporation whose relationship or expectancy has been sub- stantially disrupted. Situs Of Interference Helio Aircraft Corporation submits that, aside from substan- tial domestic interference with United States Government procurement contracts, in the case of disparagement of Helio's foreign reputation and interference and prospective foreign business, in each instance the situs of the tortious interference was the central office of the Central Intelligence Agency. While Helio Aircraft Corporation sub- mits that the Agency's acts of interference originated from the Agency's acts of interference originated from the Agency's central office, Helio does not characterize such acts of interference as LIGRATA GERALD : FORD Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Twelve "discretionary action" exempt from liability under § 2680 of. Title 28 of the FTCA. Instead, it is the belief of Helio Aircraft Corporation that the acts of tortious interference by the Central. Intelligence Agency were committed at the operational or proprietary level. Moreover, Helio Aircraft Corporation, in submitting this claim under the FTCA, submits that its action under the Act did not accrue until the full extent of damages resulting from the Agency's tortious interference were discernible and not until it was aware of the tortious acts, the injury and the casual relationship. In this regard, Helio Aircraft Corporation was not fully aware, nor had any reason to be aware, of the extent of the Agency's tortious acts and attendant damage to its fiscal integrity, until advised of the same through hearings and reports of recent date of the United States Congress concerning the activities of the Central Intelligence Agency. B. Fifth Amendment Taking The Fifth Amendment to the Constitution prevents a federal agency from taking a person's private property for public use without just compensation. Included within the definition of persons under this provision of the Fifth Amendment are corporations. General Aircraft Corporation contends that the Central Intel- ligence Agency during the time set forth in the above Statement of Facts brought about a taking of Its corporate property by a continuing process of physical events. In support of its claim under the Fifth Amendment, Helio will establish that the loss suffered as a consequence of the Agency's acts in this instance are both compensable "property" under the Fifth Amendment and, secondly, that the Agency's acts con- stitute a compensable "taking" under the Fifth Amendment. More par- ticularly, the acts of the Central Intelligence Agency constituting a taking of Helio Aircraft's property under the Fifth Amendment include the following: 1. Depriving Helio Aircraft Corporation of pro- spective business opportunities, as more fully set forth above. 2. Appropriation and use of Helio Aircraft's cor- porate name throughout the world by the Central Intelligence Agency as a "cover," as more fully set forth above. is FORD GERALD LIBRARY Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Thirteen 3. Appropriation and use of Helio Aircraft's proprietary and confidential data, draw- ings, and trade secrets in the manufactur- ing of Helio airplanes and aircraft parts at an agency facility, as more fully set forth above. Where the government chooses to bring about a taking by a continuing process of physical events, such as the continuous and cumulative past facts of the Central Intelligence Agency against Helio Aircraft Corporation, Helio Aircraft was not required to re- sort piecemeal or premature litigation to ascertain the just com- pensation of its appropriate property. Helio Aircraft Corporation was not under an obligation to bring a taking action under the six- year Statute of Limitations of § 2041(a) of Title 28 of the United States Code until it knew that the corporation's name had been sub- stantially diminished as a result of the Agency conduct. Helio's Corporate Name The name of a corporation has been recognized traditionally as an invaluable asset of a company as a property right. Helio Air- craft Corporation will establish that its company name was well estab- lished and assumed the attribute of property prior to the adverse disparagement and appropriation of its name by the Central Intelli- gence Agency. It is that consolidated good will, reputation and public identification which are entitled to protection from confusion by the operation of the CIA and those under its control. It is firmly established that a claim constitutes a compens- able property right under the Fifth Amendment if that claim is a leg- ally protected interest. As law and equity have historically protected the corporate name, it follows that the corporate name and attendant identity of Helio Aircraft Corporation is a compensable property right under the Fifth Amendment. Taking By using the corporate name of Helio Aircraft Corporation as a putative proprietary "cover" throughout the world, Helio Air- craft Corporation assumed an identity and consequent stigma tanta- mount to that of the Agency's own aviation proprietaries. Helio Aircraft in many international communities was therefore associated on many occasions with questionable activities of the Central Intel- ligence Agency and/or its aviation proprietaries, ultimately GERAL adversely LIBRARY Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Fourteen affecting Helio's worldwide reputation and ability to effectively market its unique C/STOL aircraft. Before the Agency's appropria- tion and misuse of Helio's corporate name, the company possessed a valuable asset in the form of a viable and respected reputation as a manufacturer of a unique aircraft. Following the use by the Agency of Helio's name as an ostensible aviation proprietary, that same asset was substantially diminished. In this posture, Helio Aircraft contends that its property in the form of the company's name, reputation and good will was taken by the Central Intelligence Agency for public use. The total destruction of all value of Helio's corporate name and reputation was attributable solely to the Central Intelligence Agency's appropriation of that name for its own advan- tage. In summary, Helio Aircraft will establish: (1) that its corporate name, reputation and good will are compensable property interests under the Fifth Amendment and that this property had assumed a definitive value prior to the Central Intelligence Agency's appropriation of Helio Aircraft's corporate name; and (2) that by using Helio's name, the Central Intel- ligence Agency effected a "taking" under the Fifth Amendment. Appropriation of Helio Aircraft's Trade Secrets Helio Aircraft Corporation has reason to believe that the Central Intelligence Agency, through its proprietaries, appropriated and used to its own advantage, trade secrets and other proprietary data of Helio Aircraft Corporation in the manufacture of Helio air- planes and Helio aircraft parts at the Agency's facility, as more fully set forth in the above Statement of Facts. This appropriation by the proprietaries of Helio Aircraft's trade secrets and proprie- tary and confidential data constitutes a wrongful taking of property under the Fifth Amendment, for which compensation must be made either by the proprietaries, the Central Intelligence Agency, or the United States. a FORD GERALD Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Fifteen Helio's Trade Secrets As "Property" A trade secret is generally defined as any formula, pattern, device or compilation of information which is used in one's business, and which gives him an opportunity to obtain an advantage over com- petitives who do not know or use it. A trade secret qualifies as property and, as a property right, the trade secret is protected against its appropriation or use without consent of the owner. That this principle extends to prohibit wrongful appropriation by the government of "technical data" is not novel. As a species of property, the trade secrets and confidential data appropriated by the Agency and its proprietaries are subject to the compensation requirements of the Fifth Amendment. It is clear that trade secret and confidential data are "property" under the meaning of the Fifth Amendment. In summary, Helio Aircraft Corporation will show that: (1) Helio Aircraft Corporation has maintained proprietary data, drawings and information pertaining to the process of manufacturing Helio aircraft and parts; (2) This data was secret and not of public know- ledge or of general knowledge in the trade or business; and (3) This data was appropriated by the Agency and its proprietaries to its own benefit and that this appropriation constituted a "taking" under the Fifth Amendment. Violation of the Federal Anti-Trust Laws by CIA Proprietary Companies, Their Officials and Agents, Indivi- dually and in Combination Proprietaries are business entities, wholly owned by the Central Intelligence Agency, which either actually do business as private firms, or appear to do business under commercial guise. The proprietaries possess commercial business characteristics, including requisite licenses, notwithstanding the fact that they are under the complete control of the Agency. The CIA proprie . FORD GERALD LIBRARY Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Sixteen complex, in order to expand its own economic power, has destroyed Helio's ability to compete in markets which Helio itself played an essential role in creating and has seriously jeopardized the continuing viability of General Aircraft Corporation. With respect to Helio's antitrust claims, at least three types of product markets can be identified. Each was affected by acts of proprietaries and their co-conspirators: 1. Sale of C/STOL aircraft in foreign and domestic markets; 2. Sale of transport and communication systems using C/STOL aircraft (e.g., JAARS, Naircom) 3. Sale of C/STOL aircraft research and design. The above listed products are sold for domestic military applications and in international geographical markets, primarily in Asia, Africa and South America, which require systems and equip- ment based on the utilization of C/STOL aircraft. Helio has actively engaged in marketing its products in all of the geographical markets referred to. Trade and Commerce The CIA air proprietary complex has also been intimately involved in these domestic and international markets. Indeed, it has dominated the air transport industry for these areas. The acti- vities complained of here, therefore, have had an obvious and sub- stantial effect on commerce with foreign nations and on domestic interstate commerce. Like other normal corporations, the proprietary companies are domestically incorporated, are subject to the same review as any corporate entity within their respective jurisdictions, file applicable state and federal tax returns, and obtain necessary licenses to conduct businesses. In addition, the air proprietaries compete directly with privately owned corporations such as General Aircraft. These companies, held together under the umbrella of the Pacific Corporation, a Delaware (?) corporation, have invested sub- stantially abroad and in United States banks, and have dealt and continue to deal in common stocks, debentures and commercial paper of various types. In the past twelve years the sale of stocks, for example, has resulted in publicly disclosed profits in excess of $500,000 accruing to the CIA. is FORD GERALD LISAARY Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Seventeen During the period in question, the propriétaries bought and sold substantial amounts of aircraft, carried domestic passen- gers to and from foreign locations, and maintained an extensive maintenance operation in Taiwan, among other areas, which required parts and personnel from the domestic markets. It operated like any other normal business. It used its profits for corporate and company purposes, routinely dealt with the IRS, established normal business relationships with affiliated and associated companies. Unquestionably, CIA proprietary activities substantially affected United States domestic commerce and commerce with foreign nations. In particular, there can be no doubt that the CIA acti- vities complained of here had a significant impact on commerce in the products and in the geographical markets in which Helio parti- cipated. Violations Alleged Conspiracy to Violate Sherman 1 and Sherman 2 From at least as early as 1955 until 1975, the CIA, through its officials, together with other United States Government offi- cials, officials of its operating and non-operating proprietary corporations, and officials of other corporations, engaged in acti- vities to restrain trade in the domestic and international markets for C/STOL products and services in violation of Section 1 of the Sherman Act and conspired to monopolize those markets and, in fact, did monopolize the markets for those products in violation of Sec- tion 2 of the Sherman Act. The facts disclose that the members of this conspiracy engaged in activities designed to foreclose Helio from further participation in the domestic markets for its products, namely, for United States Government contracts, among others. Although Helio successfully developed these military markets during the decade 1959 through 1969, late in the 1960's it was confronted with unexplained sales resistance from government procurement offi- cials. Helio aircraft had been evaluated extensively by military procurement agencies during the 1950's and 1960's. It now appears that such resistance was the direct and proximate result of activi- ties of CIA proprietary companies, their employees and agents, which activites included the "planting" of false and misleading informa- tion with military agencies and the active promotion of competing aircraft. FORD LIBRARY Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Eighteen The CIA, through its agents and co-conspirators, engaged in acts to foreclose Helio from further participating in the inter- national markets for its products, namely, individual foreign markets in Asia, Africa and South America, among others. Misrep- resentations and misuse of Helio's name by CIA operatives caused total losses of sales in Thailand, the Philippines and Nepal, among other places. Helio was foreclosed from participating in competi- tion for the Thai Government's procurement of turbine-powered STOL aircraft in 1972 and again in 1975 because of the CIA stigma attached to its name. The CIA and its proprietaries, acting through other United States Government officials, encouraged the foreign governments to reject Helio aircraft and refuse to deal with its personnel. In furtherance of their conspiracy to foreclose Helio from its own markets, the CIA and its co-conspirators also engaged in a series of predatory practices and unfair methods of competition and disparaged Helio's personnel and its products to its severe detri- ment. The CIA and its proprietaries operated manufacturing facil- ities and built essentially complete Helio air frames without a license from Helio, so as to support clandestine air transport and communications networks throughout Southeast Ais, and so as to earn revenues which could be sequestered from government and public know- ledge. Many of the components so manufactured failed in service. As a result, many deficiency and failure reports accumulated in FAA records concerning the Helio Courier. These manufacturing opera- tions not only unfairly and defectively copied Helio's design but used poor manufacturing techniques and inferior raw materials to produce inferior products of shabby workmanship. As a direct re- sult of these Helio performance reports, the military establishment in Southeast Asia and elsewhere refused to purchase Helio products and spread false information concerning their structural design throughout the industry. The source of this deceptive, improper and misinformative activity was the proprietary established by the CIA. Numerous other false and derogatory reports, maintenance and operating abuses originating in the proprietary complex not only tarnished the reputation of Helio products, but also the competency and integrity of its management. As previously stated, abuse of Helio's name and good will during covert Agency activities in foreign markets further contri- buted to the inexplicable sales resistance and rejection by foreign officials of Helio's products. Even now, Helio's attempts to cleanse itself of the stigma of CIA association have been fruitless. As FORD GERALD LIBRARY Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Nineteen late as 1975, twelve years after the initial acts of the CIA and its proprietaries, foreign government representatives refuse to deal with General Aircraft, since the company is still associated with clandestine activities, including the murder of public offi- cials. In engaging in the acts described above, the Agency, through its officials and in combination with its co-conspirators, acted maliciously for their own economic gain, and with the intent of driving Helio from the markets which Helio had successfully devel- oped. The effect of these violations has been to foreclose, mono- polize, unreasonably restrain and lessen competition in the defined markets in violation of Sections 1 and 2 of the Sherman Act. The facts demonstrate that the CIA, its proprietary organ- izations, and other co-conspirators conspired to restrain trade unreasonably in foreign and domestic commerce in violation of Sec- tion 1 by, among other things: 1. engaging in a boycott of Helio's products; 2. allocating territorial markets for C/STOL- related products and services; 3. disparaging Helio's officers and goods; 4. employing methods of doing business which are patently unfair; and 5. in general, trying to drive Helio out of business, or at the very least, out of the markets in which Helio has a right to com- pete. Thus, one can reasonably conclude from the totality of facts that the individuals and proprietary companies involved were engaged in a pattern of activities which, even under the rule of reason standard, amounts to an unreasonable restraint of trade in the de- fined markets. The conspirators employed tactics which prevented the development of free and open competition in those markets. Indeed, the facts demonstrate that unless Helio was willing to turn its marketing activities over to the CIA and its proprietaries, that is, unless it was willing to join the conspiracy, it could not effec- tively compete in these markets. FORD LIBRARY Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Twenty Not all restraints of trade, however, require a detailed rule of reason analysis. The CIA and its co-conspirators have engaged in at least two per se violations of Section 1. The facts are replete with examples which demonstrate a conspiracy originat- ing from actions of the CIA and its co-conspirators whereby poten- tial government and private customers were successfully persuaded not to deal with Helio. These same facts demonstrate that the CIA, its proprietary organizations, and other co-conspirators conspired to monopolize and did, in fact, monopolize at least the interna- tional markets for Helio's products in violation of Section 2 of the Sherman Act. As a direct result of the conspirators' activi- ties, Helio was unable to market its products in the foreign and domestic markets in which they either previously had been success- ful or had the potential of becoming successful. Attempts to Monopolize and Monopolization by the CIA, Its Proprietaries and Their Employees and Agents Beginning at least as early as 1961 and ending in 1975, the CIA, through its proprietaries and their officials and agents attempted individually to monopolize the markets -- both domestic and inter- national -- for STOL products and services and, in fact, did monopol- ize these markets in violation of Section 2 of the Sherman Act. The CIA and its proprietaries had created an air transport complex of immense size with operations throughout the world. This complex included one of the largest air transport operators in the world. The CIA and its proprietaries have exercised the power inherent in this complex by eliminating Helio as a competitive fac- tor in markets which the proprietaries dominated and, to some extent, in domestic military markets and in other markets. The CIA and its proprietaries abused their substantial econ- omic power and their unique position to the severe detriment of General Aircraft. They did so maliciously for their own economic gain and with a specific intent to drive Helio from markets in which it had a right to compete. They illegally sponsored and sold compet- ing aircraft; repeatedly issued misleading reports concerning the capability of such aircraft; and engaged in widespread discrediting of Helio's products and its management. "NO GERA LIBRARY Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Twenty-One The CIA and its proprietaries "embraced" each new opportun- ity open to Helio by acting to exclude Helio fromdomestic, Asian and African markets and to prevent Helio from taking advantage of new domestic and foreign opportunities as they opened. Consequently, its activities fall directly within the terms of Section 2 of the Act. The acts complained of herein demonstrate a consistent pat- tern of willful violation of Sections 1 and 2 of the Sherman Act. Taken together and in perspective, it is obvious that the actions of the CIA and its proprietaries establish a conspiracy to violate, and clear violations of the law. The proprietary companies and all individuals are subject to the sanctions of the Sherman Act. General Aircraft Corporation herein claims its damages and the puni- tive treble damages prescribed by the Act. CONCLUSION General Aircraft Corporation has herein stated a claim in the amount of $25 million and for violation of the Sherman Act, $75 million, based on actions of the CIA, its proprietaries and their employees and agents. The facts alleged will demonstrate that the Agency, its proprietaries and individuals acted willfully and know- ingly to misuse the company's name, misrepresent the company, and otherwise appropriate the company's assets and good will to their own benefit for purposes of carrying on acts illegal under United States and foreign laws and to garner revenues for the individual profit of those involved and to avoid the laws of the United States. The facts alleged will show that the aircraft operations of Helio were effectively destroyed by the acts of the CIA, its proprietaries, their employees and agents, which were so manifestly illegal and corrupt that when such acts were represented as those of Helio, Helio was thereby effectively precluded from selling and marketing opera- tions everywhere in the world. Similarly, the facts as alleged above will show that the CIA, its proprietaries and their employees and agents, by plan and design, maligned and discredited Helio's products in the United States and elsewhere in the world and actively engaged in the sell- ing of competing products. All such acts were carried on for the purpose of garnering revenues illegally for the individuals FORD and organizations involved. & GERALD LIBRARY Mr. George Bush Director Central Intelligence Agency September 30, 1976 Page Twenty-Two For all of these acts, General Aircraft Corporation claims damages as stated and further demands that the CIA, the State Depart- ment, and all other departments and personnel of the United States having the power and authority to do so, immediately assume respon- sibility for the acts complained of, announcing thereby that General Aircraft and its personnel were in no way involved in nor responsible for such acts. General Aircraft Corporation, through its counsel, requests the opportunity to meet with you and to present further facts and evidence in support of this claim. It is pointed out in this con- nection that the facts alleged consist substantially of covert acts by the Agency, its proprietaries and their employees and agents. As such, a substantial portion of the evidence of such acts lies wholly in the hands of the CIA. General Aircraft Corporation requests and demands that such facts and evidence be disclosed reasonably and promptly for purposes of settlement of this claim and without regard to allegations of privilege which might be made in matters of general public disclosure. It is requested that this claim be promptly reviewed and that voluntary disclosure of information and documents in connection therewith be made without imposing upon the company the requirement for disclosure through litigation. Respectfully submitted, Herbert L. Fenster Attorney for General Aircraft Corporation HLF/gt cc: Mr. Michael Duvall Special Assistant to the President The White House Washington, D. C. i FORD GENALD LIBRARY 1 THE WHITE HOUSE WASHINGTON October 18, 1976 MEMORANDUM FOR THE RECORD I called Tony Lapham on October 18. He advises that this matter had come up some years ago, and he does not think there is any grounds for the claim. He sees no reason for our involvement. P. Buchen FORD LIBRARY